State v. Andres C.

Summary

The court affirmed the defendant’s convictions, holding that the complainant’s therapeutic journals were not discoverable witness statements because she never signed, adopted, or approved them as a formal account for which she could be held accountable. The court also held that Brady did not require the trial prosecutor personally to review the journals and declined to adopt a constitutional prophylactic rule barring qualified staff assistance, while emphasizing that the prosecutor retains ultimate responsibility for disclosure.